FOS has published an information page for firms dealing with complaints relating to discrimination. Complaints include:
- that financial services providers have not made reasonable adjustments to take account of a customer’s disability;
- that customers have been discriminated against because of a protected characteristic;
- exclusion from accessing products because the customer does not have a mobile phone;
- being forced to select a title or gender the customer did not identify with in order to sign up for an account.
FOS says that firms need to be aware of unconscious bias when dealing with such complaints, and to not make assumptions or reach conclusions until the end of a fair investigation which is conducted with an open mind. FOS would be looking particularly at how the firm handled a complaint once the consumer has told them they have been discriminated against or treated differently. It notes the overlap between some protected characteristics and what FCA considers to be characteristics of vulnerability, which it expects firms to have regard to and take particular care to ensure vulnerable customers are treated fairly.
FOS gave examples involving:
- an autistic customer who had asked her bank to contact her only between certain hours, which the bank had ignored;
- a customer who had been refused a loan because of the age she would be at maturity without the bank having properly considered all the circumstances;
- a customer who felt he had been discriminated against because of his race when attempting to collect cash from his bank; and
- a customer quoted a higher insurance premium on the basis he had not been born in the UK